JPK, i.e. the Uniform Control File, aims to improve the operation of tax authorities, as well as to standardize electronic data that entrepreneurs submit to the Tax Office. Although JPK initially covered only large companies, now it also applies to medium, small and micro enterprises.
What is a JPK?
Standard Audit File for Tax was introduced by Article 193a of the Tax Ordinance and should be understood as books and accounting documents maintained by means of computer programs in an appropriate format, transmitted at the request of the tax authority.
Accordingly, entrepreneurs are required each month to submit to the tax authority the company data generated by the computer system, which relates to business operations made during the indicated period. They must be provided in a standardized form.
The purpose of JPK files is to streamline the operation of tax authorities and minimize unnecessary inspections. Officials, on the basis of the data received, have the opportunity to verify that the entrepreneur is not committing fiscal offenses and that he is conscientiously and timely fulfilling his tax obligations.
Rules for submitting the JPK_VAT file
VAT payers are obliged to submit tax returns for monthly (quarterly) periods to the tax office by the 25th day of the month following each subsequent month (quarter). Based on Article. 99 sec. 11b of the VAT Act, VAT returns are submitted only by means of electronic communication in a standardized XML format. At the same time, all active VAT taxpayers are obliged to provide, by means of electronic communication, information on the VAT records kept for monthly periods by the 25th day of the month following each subsequent month, indicating the month to which this information applies, regardless of whether the taxpayer settles VAT for monthly or quarterly periods.
What is the structure of the JPK VAT file?
Regardless of the specific structure, all Standard Audit File for Tax, consist of three parts.
- header – it includes both information related to the JPK (date of file creation, dates defining the scope of information reported in the file, purpose of filing, etc.) and identifying the taxpayer (company, VAT ID number, address, etc.).
- substantive – this is where the information related to the business event is placed. The data that is presented here varies depending on the structure of the JPK.
- control – contains checksums and allows you to make sure that all information is consistent with each other and provided in the correct format.
The substantive section of the VAT JPK must include:
- VAT sales records – date of sale and issuance, document number, details of the buyer of the goods,
- VAT purchase records – here you provide the details of the invoice issuer, the net amount and the amount of input VAT.
How to generate and send JPK VAT?
To generate JPK VAT, entrepreneurs can use the capabilities of their invoicing (accounting) program, use programs provided free of charge by the Ministry of Finance or use the help of an accounting office. The file should be signed electronically, using a Trusted Profile or a qualified electronic signature.
Changes in reporting data in the JPK file
On 1 January 2023, provisions amending the regulation on the detailed scope of data contained in tax returns and VAT records entered into force. These changes are related to with the entry into force of the provisions on VAT groups from the beginning of 2023. The others are simplifying and clarifying. The most important of them are presented below.
- Determining the method of recognizing collective documents
The key change introduced by the amendment is the determination of the method of reporting collective documents. Until now, invoices and documents were recognized according to the date when the tax obligation arose. However, this was impossible to implement in the case of aggregated documents, because individual transactions had different dates when the tax obligation arose. The amendment to the Regulation introduces a solution whereby transactions disclosed in the register of collective documents must be reported on the basis of the date of the last event covered by this document.
- VAT declaration accepted as the basis for issuing an enforcement title in the case of VAT groups
In the context of VAT group settlements, the changes concern the issue that the taxpayer will be a representative of the VAT group and he will be responsible for submitting JPK_VAT with the declaration. During the VAT group’s possession of the status of a taxable person, as well as after the loss of this status, the members of the VAT group, the representative and each of the group members are jointly and severally liable for its VAT liabilities. As a result, when the declaration part of JPK_V7 is submitted, it becomes an enforceable title, which makes it possible to carry out enforcement actions against each member of the VAT group.
The declaration is therefore the basis for issuing an enforcement title in accordance with Art. 3a § a point 1 of the Act of 17 June 1966 on enforcement proceedings in administration, and in accordance with art. 3b § 2 point 1 of this Act also on a member of the VAT group.
- Use of the designation WSTO_EE
WSTO_EE, i.e., the Intra-Community distance sale of goods refers to goods that are available on the date of commencement of their shipment or transportation in the territory of the state and the provision of telecommunications broadcasting and electronic services agreed in Article 28k of the Law, to entities that are not taxpayers, but have their registered office, permanent place of residence or place of stay in the territory of a member state that is not at the same time a country of record, is to be entered in JPK V7 and for this purpose the taxpayer will use internal evidence. It should be emphasized that traditional proofs, i.e. invoices or receipts, are not used. In the present situation, an independent document is used, thanks to which the tax authority will be able to check whether the limit of 42,000 zlotys has been observed. We are talking about the limit of transactions with VAT charged outside Poland.
- Clarification in the application of the GTU_08 code
Marking with the GTU_08 code should be used for goods classified according to CN 8549 as electrical and electronic waste and scrap (including precious metals), listed in item 1a of Annex 12 to the VAT Act.
- The internal evidence will replace the internal document
The Regulation introduces a change in the nomenclature both in the regulations and in the JPK file from “internal document” to “internal evidence”. This is due to the unification of nomenclature with other tax regulations, such as: regulations on the tax revenue and expense ledger, revenue records or other records.
The regulation entered into force on 1 January 2023, the exact content is available at the link below:
